Maternity Leave Around the World: Navigating Laws, Taxes and Costs

When you’re hiring across borders, maternity leave isn’t just a legal obligation — it’s a test of how seriously your company takes employee equity.

It’s also one of the areas where the disparity around maternity leave laws becomes most obvious, especially in remote or distributed teams.

While one employee might be entitled to a year off at full pay, another may only qualify for a few weeks unpaid. These differences raise real questions - not just about compliance, but about fairness, trust, and consistency.

So if you are building a global workforce, you can use this article to explain how maternity leave policies vary around the world, how that affects global employers, and what it means to support parents properly, wherever they’re based.

Maternity leave around the world: a global comparison

Every country approaches maternity leave differently. Some see it as a public good, with long, well-funded leave embedded into the national safety net. Others treat it as a private arrangement between employer and employee. Some don’t legislate for it at all.

Here’s how the landscape looks across regions.

Europe

Europe leads the way on parental leave, but even within the continent, there’s no single model.

Countries like Sweden, Poland, and Estonia offer generous packages, often shared between both parents, with high pay replacement and strong legal protections.

For instance in Sweden, there’s no dedicated maternity leave as such, but parents are entitled to 480 days of shared leave, with most of it paid at around 80% of salary.

Elsewhere, France, Germany and Italy guarantee shorter maternity periods but still provide meaningful financial support. In the UK, employees are eligible for up to 52 weeks of leave, though only 39 weeks are paid - and even then, the amount drops after the first six weeks.

What ties most European policies together is the principle of public funding. Benefits are usually paid through national insurance or social security systems, not directly by employers.

The Americas

Across North and South America, maternity leave laws are more uneven.

Canada offers up to 55% of salary (capped) through national employment insurance, and parents can share up to 69 weeks of leave depending on the plan.

In Chile, new mothers receive 18 weeks of leave, mostly paid at around 73% of earnings. Costa Rica provides 16 weeks at full pay, and Brazil mandates at least 17 weeks, with an option to extend to 180 days for companies in a special government scheme.

But then there’s the United States, where there’s still no federally mandated paid maternity leave.

Instead, eligible employees may take up to 12 weeks of unpaid leave through the Family and Medical Leave Act, though it’s worth noting that if they meet strict criteria around tenure and company size. A handful of states have introduced their own paid leave programmes, but there’s no national guarantee.

That leaves it up to employers to fill the gap, or not.

Asia-Pacific

In Asia-Pacific, parental leave policies vary as much as the economies themselves.

• India has expanded maternity leave to 26 weeks for most full-time workers, paid by the employer.
• Singapore offers 16 weeks of leave at full pay for eligible employees, with the government reimbursing a portion.
• Japan provides 14 weeks of leave at two-thirds pay, with monthly caps.
• Malaysia recently increased its entitlement to 14 weeks, also fully paid.

Australia and New Zealand take different approaches. Australia offers 12 months of job-protected leave — but only part of it is paid, and at minimum wage. New Zealand recently extended paid parental leave to 26 weeks, funded through a government scheme.

This mix of models makes it harder for employers to apply a single approach, especially when hiring across the region.

Africa & the Middle East

In many African and Middle Eastern countries, statutory maternity provisions exist but are less robust — and often rely more on the employer than the state.

In South Africa, employees can take 16 weeks off, but whether they’re paid depends on employer policy and access to the Unemployment Insurance Fund.

Nigeria offers 12 weeks at 50% pay, while Israel provides between 15 and 26 weeks depending on tenure — though only the first 15 are fully paid.

Cultural expectations around leave vary significantly too, affecting whether parents feel comfortable taking the time they’re legally entitled to.

Who pays for maternity leave across different countries?

One of the most important - and complicated - aspects of maternity policy is understanding who covers the cost. In some countries, the cost is borne by the employee themselves; in others, it’s funded by general taxation and/or social insurance of some kind.

In many European countries, the answer is straightforward: governments do.

Public funding through national insurance or social security systems ensures that leave is not only guaranteed, but financially viable for employees and employers alike. For example:

• In Norway, employees can take 49 weeks at 100% pay, or 59 weeks at 80%, fully funded by the National Insurance Scheme.
• In Spain, the full 16-week entitlement is paid by social security, not employers.
• In Germany, maternity pay is split between public health insurance and employer top-ups, with defined caps.

Other countries use mixed models.

In Japan, the health system covers two-thirds of an employee’s salary. In Singapore, employers pay for the first 8 weeks, and then claim back the rest from the government, with caps per child. These shared-responsibility models require more admin, but still aim to reduce the direct cost to businesses.

In the USA, by contrast, many employers carry the full cost, if they choose to offer paid leave at all.

And in markets where the cost is borne entirely by the company, maternity leave becomes a strategic decision. It shapes hiring budgets, benefit structures, and internal policies — especially in lean teams or small businesses.

Maternity leave: compliance, tax and local obligations

Understanding who pays is only part of the picture. Employers also need to get to grips with the tax treatment of maternity pay and the legal obligations surrounding it.

• In Ireland, maternity benefits are taxable, even when paid by the state.
• In the UK, maternity pay is treated as ordinary salary for tax purposes, but 92% can be reclaimed by employers.
• In Germany, benefits are tax-free — but they’re considered in the calculation of overall tax rates.

And it’s not just about money. Legal requirements around job protection, nursing breaks, and return-to-work timelines vary widely.

• In Brazil, employers must guarantee the employee’s role for five months post-childbirth.
• South Korea mandates two daily nursing breaks for mothers with children under one.
• Japan prohibits returning to work for eight weeks after birth, unless approved by a doctor.

Falling short on these obligations doesn’t just carry financial risk — it can damage trust, reputation, and employee morale.

What does maternity leave equity look like in a global team?

This is where things get tricky. Because even if you’re compliant with every local law, there’s still the issue of equity.

In a global team, it’s hard to justify why one employee should receive six months of paid leave while another gets none, especially when they’re doing similar roles. Those gaps are magnified in remote and hybrid teams, where cross-border collaboration is the norm.

Some companies respond by “levelling up”, creating a global minimum standard that all employees benefit from, regardless of local law. That might mean:

• Offering a consistent number of paid weeks across the business
• Topping up statutory pay where it falls short
• Offering flexible return-to-work options like part-time hours or phased re-entry
• Introducing gender-neutral parental leave policies to support all parents

But equity isn’t always about offering the same thing everywhere. It’s about ensuring your approach makes sense in context — and that no one feels left behind during one of life’s most important transitions.

Maternity leave and global expansion

If you’re expanding into new markets, maternity policy should be part of your planning — not something you bolt on later.

Why? Because generous leave can be a talent advantage — especially in competitive markets. In countries like Sweden, Germany, or Denmark, candidates expect robust parental leave. Not offering it can hurt your brand. In contrast, offering enhanced leave in under-regulated markets like the US can help you stand out.

And beyond hiring, long parental leave also affects workforce planning. You’ll need clear processes for knowledge transfer, cover during absences, and reintegration — especially in roles with high responsibility or niche skills.